RMSC Safety Sentinel- January 2017

Employers in nearly every industry now face new stringent federal rules governing slip and fall prevention that until recently applied only to the construction industry. Most of the new requirements go into effect on January 17, 2017; but bewilderingly, some of the requirements on fixed ladders are not coming into effect for two decades – in 2037. The rules finalized by OSHA cover equipment and practices designed to prevent slips and falls in the workplace focusing primarily on the training, use and maintenance of protective equipment such as fall arrest devices, scaffolds, ladders, and travel restraints, which are sometimes termed fall prevention, as opposed to fall arrest, which would actually catch a falling worker.

The final rule will have a wide scope impact by establishing new requirements for nearly all general industry employers pertaining to the use of walking-working surfaces, such as floors, stairways, guard railing, ladders, dock-boards, roofs, scaffold and any elevated work surfaces or walkways such as cat-walks, above ground storage tanks, or billboards. OSHA claims that 112 million workers employed at 7 million worksites will be covered by the new rules. According to OSHA the new regulations will be increasing the consistency between general and construction industries with the idea of improving conditions for workers and employers. OSHA estimates that the new rules will prevent 29 fatalities, and more than 5,842 injuries annually. The agency has been working on the update since 2010.

The new rules will allow employers to select the fall protection system that works best for them by choosing from a range of acceptable options including guard rails, safety nets, personal fall arrest, or positioning systems. OSHA said other changes included revised requirements for fixed and portable ladders allowing employers to use rope descent systems up to 300 ft. above a lower level. It also prohibits the use of body belts in personal fall arrest systems – which has been an area of confusion and contention the last five to ten years. Body belts will still be allowed for positioning and travel restraint only, applications might include roofing repair, or window-washing. The new rule seeks to align the older general industry standard on scaffolding, with the more up-to-date construction requirements on scaffolds. It is a similar case with personal fall arrest system requirements, which had no general industry regulations governing their use until now. In short the technology has progressed so far since these outdated standards were put in effect that they became obsolete in some respects.

The requirement for additional employee training could be the biggest change since many conscientious employers are already in compliance with most of the new requirements. Formalizing employee training curriculum and ensuring all training is completed by a “competent person” in a language the employee can understand is critical; as is updating the equipment inspection process and proper recordkeeping of these activities. Are the employees trained to use a ladder properly, when was it inspected last? We have a fall arrest harness and lanyard but was it inspected properly, is it being used in a suitable application. Employers will soon be expected to address these concerns and many others. Getting ahead of the new walking-working surface requirements is certainly advisable.

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